Selling stock by advertisement has special rules. There are exceptions in D and in a few of the rules and the OP is seeing if his plan can be done legally.
Private offerings are a complex area that I have some reading, but have no expertise. I'm not going to do the legal research required to give an answer. The OP had a good LEGAL question, but PRACTICALLY the only way he can get any money is to take a huge haircut. He's going to be selling a minority interest in a closely-held corporation. Anyone who buys is an idiot, unless the discount is huge.
I understand his situation. He has a regulated asset that he doesn't have a clue how to deal with, and instead of complying with the law, which certainly does allow you to sell privately held stock, the disclosure requirement of D are not so onerous that thousands of such transactions occur daily.
I don't understand why he wishes to take substantially more off the top by trading for "high end motor home" instead of cash. That makes no sense. If you are crying poverty you want cash money, not pay an even bigger penalty to sink your asset into something that is instantly and dramatically depreciating.
And you certainly can't avoid the SEC by bartering or using Craigslist. If he has spent 23 grand to get to this point... well he is still at square one. There are a large number of brokers, traders, and other full service firms fully capable of marketing, selling, and dealing with any resultant liabilities related to the sale of this asset.
I suspect that this cash shy behavior and having no money while having millions in private stock is the result of some other financial problem that makes having no money but a motor home desirable. At that is why no one is touching.
